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SPS Mis-operation – DRAFT Proposal for ERCOT procedures – Comments Received

SPS Mis-operation – DRAFT Proposal for ERCOT procedures – Comments Received. Darnell’s Comments: Discussion of SPS Mis-Operation.

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SPS Mis-operation – DRAFT Proposal for ERCOT procedures – Comments Received

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  1. SPS Mis-operation – DRAFT Proposal for ERCOT procedures – Comments Received

  2. Darnell’s Comments: Discussion of SPS Mis-Operation • SPS Mis-operation is not explicitly defined in the ERCOT Protocols, but the ERCOT Operating Guides section 7.2.3.3 lists events that the SPWG considers a reportable SPS mis-operation. These events are listed below: • Failure to Operate – Any failure of a SPS to perform its intended function within the designed time when system conditions intended to trigger the SPS occur. • Failure to Arm – Any failure of a SPS to automatically arm itself for system conditions that are intended to result in the SPS being automatically armed. • Unnecessary Operation – Any operation of a SPS that occurs without the occurrence of the intended system trigger condition(s). • Unnecessary Arming – Any automatic arming of a SPS that occurs without the occurrence of the intended arming system condition(s). • Failure to Reset – Any failure of a SPS to automatically reset following a return of normal system conditions if that is the design intent.

  3. Responsibilities for Investigation • When an SPS mis-operation occurs, the TO shall provide to ERCOT the same written documentation outlined by the Operating Guides, stating what the cause of the mis-operation was and outline what steps have been made to ensure that this same misoperation will not happen in the future within 5 business days (ERCOT Operating Guides, section 7.2.3.3). Again, ERCOT System Operations, shall make the final determination as to whether or not the SPS mis-operated. • ERCOT Operations shall make the final determination whether or not that SPS had mis-operated, following the process outlined below:

  4. Investigation- continued • ERCOT System Operations and Transmission Services shall independently review the report filed by the TO. • ERCOT System Operations and Transmission Services shall meet and discuss the results of their review. Any remaining questions or comments remaining shall be sent to the TO. • ERCOT System Operations and Transmission Services shall review the replies from the TO, if any, and decide whether or not the SPS has mis-operated. • The final decision shall then be sent to the Director of System Operations and the Director of Transmission Services for final approval of the decision, which will then be sent out to the TO and to all relevant working groups, task forces, and subcommittees. • Should an SPS mis-operate 2 times or more for the same reason within the 5 year period of the SPS, ERCOT may request that the SPS be disabled until further review of the SPS and its mis-operations can be made.

  5. Preston Comments • With regard to the last item stating:*       Should an SPS mis-operate 2 times or more for the same reason within the 5 year period of the SPS, ERCOT may request that the SPS be disabled until further review of the SPS and its mis-operations can be made. • What if the SPS cannot be disabled without causing an unacceptable reliability situation?  I suspect this will usually be the case.  Then what to do?  This will leave ERCOT stuck with an impossible to solve problem.  A more realistic last statement to make would be to require a redesign the SPS so that it will perform as designed for an interim period until additional transmission can be constructed to remove the need for the SPS.

  6. Paul Rocha Comments • .    There is a slide that indicates the TO will provide documentation to ERCOT when an SPS misoperates.  In the same slide, it says ERCOT will make the final determination of whether a misoperation occurred, and there is a reference to "with the advice" that I didn't follow. •       Since it is unclear and potentially contentious whether a proper operation or misoperation occurred (otherwise ERCOT would not need to make a final determination), it seems that the TO should provide documentation whenever the SPS operates, properly or otherwise.  That way, there isn't any ambiguity as to when a TO should provide documentation.  As written, the TO may believe an SPS operation was proper, not send any documentation, and risk being accused of not complying with the requirement. Alternatively, to avoid such accusations, the TO may send documentation and then risk conceding a misoperation did in fact occur (since the requirement is only to document "misoperations"), when the TO may believe otherwise. •      That's why I propose documenting all SPS operations.  I wouldn't want this to become overly burdensome, but I don't think that's the case since, as I understand it, SPSs are intended to address rare circumstances, and there have been few SPS operations in ERCOT.  If my understanding is incorrect and SPS operations are common, then we probably need to rethink this proposal.

  7. Paul Rocha Comments •    Along with my first recommendation, it seems we should also require the TO to report when an SPS fails to operate under conditions for which it should have operated.  This might not be as clear as when an SPS operates but my thought is ERCOT could advise the TO if this appears to have been the case and the TO has not sent in a report. • 3.    Assuming the conditions under which an SPS should operate are rare (so that this process does not become overly burdensome and unmanageable), it might be desirable for ERCOT to evaluate TO documentation after an SPS operation (or failure to operate) and provide a recommendation concerning whether a misoperation occurred, with final review / approval by ROS and/or TAC.

  8. Randy Jones Comments • It would seem that the most rational approach would be to leave it to the collective ERCOT staff expertise to determine whether the SPS should be temporarily disabled.  A lot of that decision would hinge on the time scale ERCOT would be looking at, and as Gene points out, the impact to system reliability.  Objectivity must and will be a large part of the decision making.  Did the scheme misoperate for two different reasons four years apart?  Did it misoperate for the same reason twice within three months of being installed.  Let's not throw the baby out with the bathwater, these SPSs make an acceptable bridge to a good long term solution.....new transmission.  I believe David has it right.  Let's leave the language as he's proposed.

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